I cannot recall a year that didn’t start with me thinking that this one is going to present some unique challenges.
There is no getting away from the fact that regulation is centre stage for trade bodies. Representing members’ interests to Government and regulators has to be the primary means by which we can return value to members, and there is plenty to have a go at. However, there is a mass of detail to wade through, and the chief concern is that a structure needs to be established that allows a diverse and large intermediary market to continue to flourish. The public need to have easy access to mortgage advice and that advice needs to be free, if the intermediary wishes to provide it for free.
While the current proposals are helpful, especially as they include the prospect of agency relationships through the app- ointed representatives regime, but there is a worry about the burden of documentation, and the absence of a ‘reasons why’ letter seems mysterious. However, IMLA is concerned foremost about a structure that intends to treat products differently depending on the Financial Services Authority’s ( FSA) view on risk.
On top of this there is a review of the Consumer Credit Act underway in Britain, and in Europe there is a separate, and not entirely co-ordinated review of credit regulation that is likely to further complicate regulation in the UK. All of this needs to be considered and responded to quickly in order to have a chance to influence direction.
There is also the trade body for intermediaries. Whichever way you look at it, vital as intermediaries are to the future of our members, IMLA is not itself a trade body for intermediaries and cannot therefore properly or fully represent their interests.
There is plenty to work on but we need to be sure that we have selected our targets carefully and can focus our energy on causes where it can really make a difference.
IMLA makes no pretence that it is in a better position than anyone else to predict the future of the housing market, but it can provide members with access to expert opinion and a programme of targeted, bespoke research.
When considering the year ahead, it is difficult not to conclude, as most analysts already have, that a correction in the housing market is overdue. However, it is factors elsewhere: in world politics, the global economy and in consumer confidence that will decide whether the correction is measured and manageable or altogether more traumatic.
John Heron, chairman of the Intermediary Mortgage Lenders Association (IMLA)